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9/23/20265 min read
The Stablecoin Market War
A stablecoin issuer's deposit at a commercial bank is recorded twice. It's an asset on the issuer's reserve statement and a liability on the bank's equity side. The two objections to the 60% rule are the same comment read from two different perspectives.
Tether's argument revolves around the asset aspect. Bank deposits are unsecured liabilities for a leveraged institution. Deposit insurance only covers a small portion of the balances of institutions of this size, so the remainder is tied up with other unsecured creditors if the bank fails. In contrast, treasury bills are a direct obligation of a sovereign state without intermediaries. Therefore, forcing 60% of reserves to shift from treasury bills to bank deposits would replace country risk with bank credit risk, which contradicts the objective of a rule aimed at ensuring reserve safety.
The ESCB's argument revolves around the liability aspect. Stablecoin reserves are not fixed corporate deposits. They increase when tokens are issued and decrease when they are redeemed, and redemptions are concentrated precisely during periods of market stress. A bank that has lent against those deposits will see its funds withdrawn at the worst possible time. It's the classic conduit for massive withdrawals, introduced into the banking system through a regulation aimed at making stablecoins safer. Both are true. Mandatory deposits make both the issuer and the bank more vulnerable at the same time, because that vulnerability is essentially the same item on the balance sheet being reviewed twice.
Tether's counter-argument has empirical grounds.
This argument is not hypothetical. In March 2023, Circle revealed that $3.3 billion in USDC reserves were held at Silicon Valley Bank when the bank went bankrupt. USDC lost its fixed exchange rate and traded as low as around 87 cents for a weekend before US authorities intervened to support depositors of SVB and the exchange rate recovered.
That incident is the clearest illustration of the mechanism that Tether describes. The issuer did nothing wrong. Their reserves were real. The bankruptcy occurred through a bank they used to hold the cash, and stablecoin holders bore the consequences until the government intervened.
A regulation requiring 60% of reserves to be deposited in commercial bank accounts would make that risk mandatory, not optional. Tether's Q2 report showed $114.96 billion in Treasury bills out of total assets of $187.75 billion, compared to $183.64 billion in liabilities and a surplus of approximately $4.11 billion, with $184.6 billion in USDT in circulation. A restructuring toward a deposit-centric approach would mean shifting tens of billions of dollars from the safest instrument available to bank debt.
The scale needs to be clearly stated, as it's often misunderstood. MiCA applies to tokens issued or offered within the EU, and a MiCA-compliant USDT is most likely a European token issued separately with its own reserve fund, rather than a restructuring of the global fund. The 60% figure would apply to that fund, not to the $184.6 billion. But the principle is what drove the decision, and Ardoino has been consistent on this for the past two years.
The alternative focuses on the actual risks.
The alternative proposed by the ESCB is a better regulatory design, and the reason is that it measures what is important rather than being a substitute indicator. The question that stablecoin reserve regulation needs to answer is whether the issuer can meet withdrawal requirements immediately. The deposit threshold answers another question, namely where the funds are deposited, and the assumption of location is synonymous with usability. A liquidity test asking about the ratio of reserves maturing within one to five business days would directly relate to the ability to withdraw funds.
Short-term Treasury bills meet that test without concentrating credit risk on the banks. They can be sold on the world's deepest markets or simply allowed to mature within days. By liquidity standards, an issuer holding almost all of its short-term government bonds would be compliant, which is very similar to what Tether has done.
The ESCB also acknowledged something that regulators rarely record. Their records note significant challenges in enforcing the rules, because non-compliant cryptocurrency companies still have access to EU customers. That is the acknowledgment that the line is leaking. USDT circulates among European users regardless of its licensing status, meaning that a regulation strict enough to remove the largest issuer from the regime does not eliminate the risk. It only removes oversight.
Assessment and Conclusion
The most common misconception about this story is that removing the 60% rule will pave the way for Tether to enter the European market. It only removes one hurdle that Ardoino has raised, but doesn't address the others. The MiCA license requires an EU-authorized entity, governance and custody agreements, regular reporting, and oversight by a national competent authority. Tether is incorporated in El Salvador and has built its business model on operating outside the oversight of any jurisdiction, while selectively cooperating with US authorities on enforcement, including freezing approximately $475 million USDT related to Iran this year. These are structural commitments, not a single regulatory clause.
Tether also suffered the costs of being excluded. They stopped issuing EURT and completed a phased withdrawal by November 2025, citing the European regulatory environment, and USDT was delisted for EEA users on a number of exchanges once MiCA took full effect. Circle's euro and dollar tokens filled much of that void. Re-entering a market where market share has been redistributed is a different matter than never having left.
And this process is slow. The ESCB's feedback is input for the Commission's review process, not legislation. Any changes require the Commission to propose amendments and for legislators to jointly pass them, which takes at least several quarters. The 30% and 60% thresholds apply throughout.
What Ardoino achieved this week was position. Tether spent two years arguing that a regulation made stablecoins less secure, and the institution primarily responsible for European financial stability has now issued a structurally similar statement for its own reasons. That benefits a company whose legal stance is often described as evasive rather than compliant. Whether they will apply for a license is another question, and nothing in this week's developments suggests that is imminent.
Disclaimer: The content in this article is for informational, research, data analysis, and reference purposes only regarding the cryptocurrency market. All opinions, assessments, forecasts, or opinions reflect the author's perspective at the time of publication and do not constitute investment advice, solicitations for buying or selling, trading recommendations, advertising, marketing, or promotion of any financial products, services, or cryptocurrencies. Mentions of projects, tokens, protocols, exchanges, wallets, or cryptocurrency service providers (CASPs) are for research, analysis, or informational purposes only and should not be construed as endorsements, recommendations, or guarantees in any way. HCCVenture does not broker, advertise, market, promote, or connect users in Vietnam with any cryptocurrency services from CASPs. HCCVenture does not accept asset custody, investment mandates, manage assets, or execute transactions on behalf of clients. All investment decisions are made entirely through the reader's own research (DYOR), evaluation, and responsibility; HCCVenture is not liable for any losses or damages arising from the use of or reliance on the information presented in this article.
Compiled and analyzed by HCCVenture
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